1.

That the plaintiffs are a law-abiding citizen of this country and residence
of Mahavir Enclave Enclave Part-3, Ward No-105 the Adhar Cards of
plaintiffs is annexed herewith as [ANNEXURE A]
2. That the defendant No 1 is a Cellular operation company M/s Indus
Tower Ltd, building No. 10, Tower B, 4 th Floor who install mobile Tower
over whole India.
3. Defendant No 2 is municipal Corporation of Delhi office of the executive
engineer [BLDG]-II west Zone, Second Floor, Dr. Sahaib singh verma,
Nigam Bhawan Shivaji Enclave, Near West Gate Mall, New Delhi-
110027 who gave permission to defendant No1 for erection of roof top
pole at defendant no 3 properties.
4. Defenant No 3 is a residence of Subhalaxmi Apartment, 3 rd floor F-162,
Gali No-82, Mahavir Enclave Pt-3, N.D.-59 and also have the ownership
of the rooftop of the said apartment.
5. That the defendants no 1got the permission for Erection of roof top pole
RTT/RTP at property of defendant No -3 Property No. Plot No.37, New
No. F-162, Khasra No. 111/10/2, Village Palam, Mahavir Enclave, new
Delhi-110059 from the defendant No-2 vide its permission dated
12/02/2024 and application no is /EE[B]-II/WZ/2024/AE. The permission
dated 12/02/2024 and application no is /EE[B]-II/WZ/2024/AE is
annexed herewith as [Annexure B].
6. That the defendant No-3 have already install Antennas & Mounting
Equipment and Splitters, Couplers & Attenduators on the roof top of their
building since XXXX. The colored photograph of the already installed
Antennas & Mounting Equipment and Splitters, Couplers & Attenduators
is annexed herewith [Annexure C]. The defendant no 1 now got the
permission for erection of roof top pole RTT/RTP on the roof top of the
defendant No-3.
7. That the locality of Mahavir Enclave Enclave Part-3, Ward No-105 is
densely populated and approx Fifty Thousand people are living in the
said locality. They are constrained to risk their life in thread under the
exposure of harmful electromagnetic radiations. Multiple antennia is
going to be installed in extremely close proximity of the residence of
petitioners.
8. That the petitioners make an efforts to stop the erection of roof top pole at
defendant no 3 properties but defendant No 3 wife gave threat remark to
petitioners that she will implicate all of them in false rape case and file
FIR against all of them if they ever dare to stop the erection of the roof
top pole at her apartments. The said incident is recorded by petitioners in
their phone. The same is annexed herewith as [Annexure D].
9. That the petitioners gave a complaint regarding the erection of roof top
pole at defendant no 3 properties to the Deputy Commissioner of Police,
Dwarka Sector-19 vide complaint dated 17/02/2024 and petitioners also
gave the complaint to the Deputy Commissioner of MCD Rajouri Garden
vide complaint dated 19/02/2024 but noting effective step was taken by
the above concerned government body. The complaint receiving of
complaint dated 17/02/2024 & the receiving of Complaint dated
19/02/2024 is annexed herewith as [Annexures E Colly].
10.That the defendants completely overlooked the adverse effects from the
EMF/radiation from the mobile tower including effects on birds, bats,
honey bee, etc. Some of the health effects reported are effects on cell
growth, cell differentiation, DNA damages, altered immune system,
hormornal effects, pervassice impairment of metabolic and reproductive
system, effects on fertility, reproduction and health of off-spring, risk of
glioma (a malignant brain tumour), sleep disorders, confusion, anxiety
and depression and appetite sisturbance, etc.
11.That in the locality of Mahavir Enclave Enclave Part-3, Ward No-105
there are ample numbers of old age persons who suffers from old age
diseases, five to six ladies are even pregnant they all are at open risk from
the EMF/Radiation from the mobile tower.
12.